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AHIP takes issue with risk scores, benchmark calculations

The changes are happening while the Administration is considering other efforts, such as amending the safe harbor rule on rebates.

Susan Morse, Managing Editor

A proposed notice to significantly reduce risk scores, particularly for low income enrollees, and the failure to adjust county benchmark calculations could potentially undermine the ability of Medicare Part D and Medicare Advantage plans to offer affordability and stability in the market, according to America's Health Insurance Plans.

AHIP's comments to the Centers for Medicare and Medicaid Services are a response to the 2020 advance notice and draft call letter for Medicare Advantage and Part D Plans.

The Medicare Payment Advisory Commission has recommended adjusting county benchmark calculations, AHIP said.


The notice process is happening while the Administration is considering other major changes that could dramatically impact the Medicare Advantage and Part D programs in 2020, AHIP said.

These include legislative and policy changes to lower drug prices and reduce out-of-pocket expenses, including an amendment to the safe harbor rules relating to rebates for Part D plans.

Currently the rebates are passed on to health plans, which use them to lower the price of premiums. CMS has proposed ending this practice in favor of having the rebates passed directly to consumers.

There is also a proposed rule imposing new Medicare Advantage interoperability and patient access requirements, AHIP said.

Uncertainty in these areas is expected to continue past the June 3 bid deadline for MA and Part D plans. The bids are submitted on or before the first Monday in June that include the benefits and pricing for each MA and Part D plan for the upcoming year.

AHIP supports the provision addressing new benefit flexibility for chronically ill enrollees.


Nearly 22 million seniors and people with disabilities – a third of those eligible for Medicare – have chosen to enroll in the Medicare Advantage program, and more than 45 million seniors and individuals with disabilities are covered under Part D, AHIP said.


"To ensure that Medicare Advantage can continue to deliver value, we urge CMS to enhance its transparency and engage with stakeholders outside of the rate notice process in developing the risk model and in making other payment policy changes that have major implications for the benefit packages that Medicare Advantage plans can offer to enrollees."

Twitter: @SusanJMorse
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